Imported capital goods credit allowed where duty payment was verified and the six-month limit was treated as inapplicable to capital goods.

Imported capital goods credit was treated as admissible where Customs had verified duty payment and the receipt, installation, and use of the goods in manufacture of dutiable final products were undisputed. In that setting, the absence of a certified duplicate Bill of Entry did not defeat credit once the factual basis for duty payment was established. The six-month restriction was treated as applicable to inputs, not capital goods, in line with the departmental circular referred to in the record. On that basis, credit was allowed and the Revenue challenge failed.

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Issues: Whether credit on imported capital goods was admissible on the basis of the reconstituted Bill of Entry when duty payment was verified by Customs, and whether availment of credit beyond six months was barred.

Analysis: The duty payment on import of the capital goods was confirmed by the Customs authorities, and the receipt, installation, and use of the capital goods in manufacture of dutiable final products were not in dispute. In these circumstances, the requirement of a certified duplicate Bill of Entry did not defeat the credit when the factual basis for duty payment stood established. On the question of time limit, the six months restriction was treated as applicable to inputs and not to capital goods, consistent with the departmental circular relied upon in the record.

Conclusion: The credit was held to be admissible and the Revenue's challenge failed.

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